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Case 1:15-cv-07433-LAP Document 1330-15 Filed 01/05/24 Page 5 of 43 improper Fifth Amendment objections because there is no risk of incrimination because these proceedings will be under seal. Moreover, under the Protective Order issued by the New York case, Ms. Giuffre’s counsel (and counsel for Ms. Maxwell,' the Defendant in the New York case) are forbidden to disclose the materials for “any purpose except the preparation and trial of this case.” Protective Order, 4. Under the terms of the protective order, all materials secured in the case will be destroyed at the end of the case. Protective Order, 12. And while the Protective Order does not bar the use of confidential materials at trial, Protective Order | 13, Ms. Giuffre’s counsel represent that they will not use at trial any documents that Epstein produces without first notifying Epstein and seeking leave of Court to do so, As a result, Epstein can provide documents to Ms, Giuffre, allowing her to investigate this case without compromising any interest that Epstein may have in avoiding self-incrimination. Additionally, the entire deposition has already been designated as “confidential” by defendant Maxwell, making these proceedings subject to a protective order. See Motion to Compel at Addendum A (copy of protective order). To enforce that previously-entered confidentiality order from the Southern District of New York, these proceedings should be confidential as well. Moreover, in such circumstances, there is no substantial risk of incrimination from the mere production of documents to Ms. Giuffre’s counsel, who are subject to the protective order. See generally Mare Youngelson, The Use of 26(c) Protective Orders: "Pleading the Fifth” Without Suffering “Adverse” Consequences, 1994 Ann. Surv. Am, L, 245 (1995); see also Palmieri v. State of New York, 779 F.2d 861 (2d Cir. 1985). ‘Tt may be relevant to note that defendant Maxwell has not sought any documents from Epstein, and thus the only issue presented here is the extent to which Ms. Giuffre can use the documents. 3